Interaction, Inc./State of Texas v. State of Texas/Interaction, Inc.

CourtCourt of Appeals of Texas
DecidedMay 4, 2000
Docket03-99-00358-CV
StatusPublished

This text of Interaction, Inc./State of Texas v. State of Texas/Interaction, Inc. (Interaction, Inc./State of Texas v. State of Texas/Interaction, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Interaction, Inc./State of Texas v. State of Texas/Interaction, Inc., (Tex. Ct. App. 2000).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-99-00358-CV

Interaction, Inc./State of Texas, Appellants


v.



State of Texas/Interaction, Inc., Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 261ST JUDICIAL DISTRICT

NO. 95-00056, HONORABLE MARGARET A. COOPER, JUDGE PRESIDING

The State of Texas sued Boutros Investments, Inc. No. 7 (Boutros 7) and Interaction, Inc. to recover delinquent taxes owed by Boutros 7. Because both defendants failed to answer, the trial court rendered a default judgment against Boutros 7 and Interaction. Interaction filed a petition for bill of review alleging it had not received notice of the State's suit. The trial court granted the petition, and after a trial to the court, rendered judgment for the State. On appeal, Interaction raises three points of error: that the evidence is factually and legally insufficient to support the judgment, that there is no basis in law to support a judgment against Interaction for taxes owed by Boutros 7, and that the judgment is not supported by the findings of fact. On cross-appeal, the State asserts that the trial court erred in granting the bill of review and proceeding with a trial on the merits. We will reverse the trial court's order granting the bill of review and render judgment that the trial court's default judgment be reinstated.

FACTUAL AND PROCEDURAL BACKGROUND

This dispute involves liability for gasoline and sales taxes that Boutros 7 incurred as operator of Webster Conoco, a convenience store that sells gas, groceries, beer, and other incidentals. An audit of Boutros 7 by the Comptroller for the period between 1989 and 1991 revealed unpaid sales taxes amounting to $7,432.95 and gasoline taxes totaling $213,185.35. The Comptroller conducted a hearing on September 11, 1991 and thereafter issued Certificates of Delinquency against Boutros 7.

Pierre Tanios owned Boutros 7, which leased the Webster Conoco premises from Dwayne T. Warner. At some point not clear from the record, Tanios moved to Louisiana. Warner testified that Assad Boulos, vice president of Interaction, called to tell him that Tanios had moved and that Interaction was taking over the Webster Conoco store. Warner recorded a deposit of $1700 from Interaction made on September 14, 1991, representing rental fees collected for the Webster Conoco. Interaction obtained a sales tax permit for the store on September 28, 1991 and made its first taxable sale at this location on October 1.

The State sued Interaction as well as Boutros 7 for the delinquent taxes alleging that Interaction was either a statutory or common-law successor to Boutros 7. The State attempted to serve citation on Interaction's registered agent, Simon Raef Assaad, at an address in Humble. The officer's return indicated that the citation was not executed because Simon Assaad had moved to Lebanon. The name and title of Interaction's vice president, Assad Boulos, and his address in Spring were handwritten on the return. Rather than serving Boulos, the State then substituted service on Interaction through the Secretary of State. The Secretary of State forwarded the citation to Interaction's registered address. The State obtained a default judgment against Interaction and Boutros 7 for $226,993.38, plus $10,000 in attorney's fees, plus interest and costs of suit. Nothing in the record indicates that notice of entry of the default judgment was sent to Interaction.

Interaction learned about the lawsuit and the default judgment when the State garnished Interaction's bank accounts. Thereafter, Interaction filed a petition for a bill of review alleging it had no actual or constructive notice of the lawsuit. The trial judge granted the bill of review based on the parties' stipulations and arguments of counsel and set the cause for trial. Boutros 7 was not a party to the bill of review or the trial.

The trial court held Interaction liable for the delinquent taxes. In its conclusions of law, the trial court held that Interaction was a continuing enterprise of and a successor to Boutros 7 and that the two corporations operated as a single enterprise. It also held that Interaction was used as a sham to perpetrate a fraud on the State. On appeal, we will first consider whether the court erred in granting the bill of review. If the State's cross-appeal is sustained, we need not address the points of error raised by Interaction complaining of the judgment rendered at trial.



DISCUSSION

A bill of review is an independent, equitable action to set aside a judgment that is no longer appealable or subject to a motion for new trial. See Axelrod R & D, Inc. v. Ivy, 839 S.W.2d 126, 128 (Tex. App.--Austin 1992, writ denied). In general, for a party to successfully invoke a bill of review, it must allege and prove that 1) it had a meritorious defense to the cause of action alleged to support the judgment; 2) which it was prevented from making because of fraud, accident, or wrongful act of the opposite party 3) that was untainted by any fault or negligence of its own. See Alexander v. Hagedorn, 226 S.W.2d 996, 998 (Tex. 1950). However, when a defendant does not receive notice of a lawsuit, the defendant is relieved of its burden to prove that fraud, accident, or wrongful act prevented it from making its defense. See Texas Indus., Inc. v. Sanchez, 525 S.W.2d 870, 871 (Tex. 1975) (per curiam). When there is no notice, defendant's lack of fault or negligence is established. See Caldwell v. Barnes, 975 S.W.2d 535, 537 (Tex. 1998).

In reviewing a bill of review, every presumption is indulged in favor of the court's ruling, which will not be disturbed unless it is affirmatively shown that there was an abuse of judicial discretion. See Harris v. Elm Oil Co., 183 S.W.2d 216, 218 (Tex. Civ. App.--Texarkana 1944, writ ref'd w.o.m.). A trial court abuses its discretion when it acts in an unreasonable and arbitrary manner, or without reference to any guiding rules or principles. See Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238, 241-42 (Tex. 1985). Because it is fundamentally important that finality be accorded to judgments, bills of review "'are always watched by courts of equity with extreme jealousy, and the grounds on which interference will be allowed are narrow and restricted.'" Hagedorn, 226 S.W.2d at 998 (quoting Harding v. W.L. Pearson & Co., 48 S.W.2d 964, 965-66 (Tex. Comm'n App. 1932, holding approved)).

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